Privacy Policy

Introduction

Welcome to EZOO’s privacy policy.

EZOO respects your privacy and is 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.

EZOO is the controller and responsible for your personal data.

Evolution Auto Limited T/A is authorised and regulated by the Financial Conduct Authority (Firm Reference Number: 813208) as a broker, not a lender.

Evolution Auto Limited is registered with the ICO (Registration Number ZA431672).

This Privacy Policy (together with our Cookie Policy, Website/Mobile Application Terms and Conditions, Product(s) Terms and Conditions, and the applicable information provided as part of an application process/contract of hire) sets out the basis upon which we will process personal information that:

• is collected from you when you use this website;
• is collected from you when you apply for/express an interest in/use a product or service offered by or through us;
• we obtain during the provision of that product or service;
• is provided to us through ezoo.uk (“Website”), our mobile application, over the phone or through social media.

Please read this Privacy Statement carefully, as it contains important information to help you understand our practices regarding any personal information that you give to us.

By accessing, browsing or otherwise using the Website or mobile application or using products or services offered by us or through us, you confirm that you have read and agree to this Privacy Statement. If you do not agree with any part of this Privacy Statement, you should not use the Website or mobile application, or apply for/use products or services offered by us or through us. If you are applying for one of our products or services online or by phone and do not agree with any part of this Privacy Statement, you should not continue with your application.

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.

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.

Contact details

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

Full name of legal entity: Evolution Auto Limited (trading as ‘EZOO’)

Email address: [email protected]

Postal address: Friars House, Manor House Drive, Coventry, CV1 2TE

Telephone number: 0203 9500 270

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator 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 15 JUNE 2023.

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.

1. What Information Do We Collect

Personal Data

We may collect personal information (which means any information about an individual whose identity is apparent or can be reasonably ascertained from such information) from you in connection with a service or product provided to you by us, including:

• Identity Data: Including first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender, and proof of identity (including selfies to confirm the proof of identity relates to you, and copies of/details of your driving licence).
• Contact Data: Including billing address, delivery address, email address and telephone numbers.
• Employment/Income Data: Including current and previous employers, nature of work, place of work, transport to/from work, occupations, income, and proof of income.
• Expenditure Data: Including current and expected outgoings, including those from people financially dependent on you.
• Credit Data: Including credit history and publicly held information such as bankruptcies or County Court Judgments.
• Bank Account Data: Including transactional data.
• Credit Card Data: Including card numbers.
• Insurance Data: Including previous or current accidents/claims, you may have/have had.
• Technical Data: Including 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.
• Transaction Data: Including details about payments to and from you and other details of hire agreements you have or have had with us.
• Profile Data: Including your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data: Including information about how you use our website, products and services.
• Marketing and Communications Data: Including your preferences in receiving marketing from our third parties and us and your communication preferences.
• Survey Data: Including your response to surveys done by us, and authorised third-parties
• Vehicle Usage & Location Data: (if you hire a vehicle from us): Including data collected relating to your vehicle location information, mileage, journey and battery charge levels, drive economy and whether the car is locked or unlocked.
• Incident Data (if you hire a vehicle from us): Including any information regarding accidents, incidents, collisions or other damage to our vehicle or by a person hiring our vehicle to others.
• Video Footage (if you hire a vehicle from us): Including footage captured through in-car dashcam technology on the occurrence of events of different severities, for example, accidents, collisions, incidents, other damage, or if there is sudden braking. This also may include CCTV footage captured on our premises.
• Sensitive Data: Including health information regarding a disability, illness or impairment where you inform us of such circumstances. (See our section on Sensitive Personal Data below for further details).

Where information fields are marked as mandatory on any form that you enter information into, you will need to provide such information in order for us to continue with your application/complete the service. Should you complete mandatory sections of the form, but not complete the whole form, we may use the information provided to contact you to provide support with the service.

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 service/contract we have or are trying to enter into with you (for example, to hire you a car). In this case, we may have to cancel the service/hire agreement you have with us, but we will notify you if this is the case at the time.

Aggregated Data

We also collect, use and share Aggregated Data, such as statistical or demographic data.

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.

Third-party Links

This website/application may include links to third-party websites, plug-ins and applications, such as social media links. 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.

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 hire you a car). In this case, we may have to cancel a hire agreement you have with us, but we will notify you if this is the case at the time.

2. 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 through our online platform, by post, phone, email or otherwise. This includes personal data you provide when you:

• apply for or purchase/use any product or service from us;
• create an account on our online platform;
• subscribe to our service or publications;
• request marketing to be sent to you;
• provide information to us on our website, our mobile application, in writing, through social media, or over the phone (including via call recording);
• register an interest in a job vacancy, or a product and/or service,
• request information or assistance from us;
• enter a competition, promotion or survey;
• make a complaint; 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. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy 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:
  • analytics providers such as Google based outside the UK;
  • search information providers.
  • Contact, Financial and Transaction Data from providers of technical, payment, delivery services.
  • Identity and Contact Data from publicly available sources.
  • Credit check report data from credit reference agencies and/or Open Banking account information providers.
  • Driving licence data providers.
  • Identity and Contact Data, anti-transaction-fraud and anti-money-laundering data providers.
  • Driving Data providers, including telematics data obtained from the black box in any vehicle you hire from us.

3. Lawful Basis For Processing

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 service you have requested, e.g. hire agreement 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.

The lawful bases on which we will gather, use and processes your data can be defined as consensual, contractual, for legal obligations or where we have a legitimate interest.

Note: We may process your personal data on more than one lawful basis, 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.

Consent

Consent to the processing of personal data for one or more specific purposes is outlined in detail within this privacy statement – however, in summary, they include, but are not limited to:

• In connection with the introduction and administration of a service you have requested from us;
• To enable us to review if the service you requested is right for your current/future circumstances;
• To enable us to provide you with information on the current services available to you and to provide you with information on any future services for which you may become eligible;
• For the purpose of introduction and administration of related insurance policies;
• For marketing activities.

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.

Contractual

This is where the processing is necessary for the performance of a contract to which any applicant is a party or in order to take steps at the request of the applicant prior to entering into a contract. These activities place requirements on the business to collect and process personal information in order to fulfil its obligations under the introduction and/or fulfilment of any contractual rights, agreements or expectations of any product/service applied for. These may include, but are not limited to:

• Gathering of financial information and performance to understand your creditworthiness or affordability in relation to a product or service;
• Tracking of any vehicle being hired.

Legal Obligations

This is where the processing is necessary in order for us to adhere to legal and regulatory obligations. These obligations include, but are not limited to:

• HM Government for money laundering and financial crime prevention;
• Financial Conduct Authority (FCA) to evidence robust systems and controls;
• Information Commissioner’s Office (ICO) to evidence appropriate technical arrangements for the processing and control of data.

Legitimate Interests

This is where the processing is necessary to enable us to develop and improve the product/service offering or to track whether our existing products/services are functioning as intended.

Any data held for this purpose will be pseudonymised and retained only for the purpose of improving the products and services we offer and will not be used for any other purpose, including communicating directly to you as an individual data subject.

4. Use of Your Information

Your information will be used by us in connection with the following purposes:

Service/Product Provision and Internal Processing

This means where we need to use the information;

• to register you as a new customer;
• to provide the product or service that you applied for, or elsewise purchased from us or via us;
• to allow us to consider and process your application for a product or service and/or enable a third party to provide you with a suitable product or service tailored to your needs;
• to evaluate risk in connection with the provision of products or services, in particular, insurance, credit and credit-related services (including insurance and lending risks). For further information, see the section below on Credit Checking and Automated Decision Making;
• to allow us to provide a quotation and process your application; to enable a third-party insurer to provide you with a suitable insurance product or service tailored to your individual needs;
• to confirm, update and improve our customer records;
• to validate claims (e.g., insurance and fraud claims) and to report on the performance of an account;
• to troubleshoot problems with the Website or mobile application, or to customise your experience on the Website or mobile application;
• to assess what forbearance options are appropriate if you are in financial difficulties;
• to recover debts/money which you owe us;
• to provide you with any information on the products or services you hold with us;
• to administer competitions or prizes;
• to personalise any interactions with you;
• to manage any payments, fees or charges relevant to the product or service you applied for/are contracted for/purchased through us.

Management of Relationship

This means where we need to use the information;

• to manage, analyse, understand and develop your relationship with us;
• to inform you about improvements to the Website or mobile application;
• to keep you informed of any of our other/new products and services and identify and market products and services that may be of interest to you, where you have chosen to be made aware of this;
• to assist in any future applications to us.

Queries or Problems

This means where we need to use the information;

• to respond to any queries, questions or complaints that you may have;
• to contact you if there are any maintenance, servicing or other issues with any product or service you have applied for/have with us;
• to contact you if a form you have started is incomplete.

Training, Service Review and Statistics

This means where we need to use the information;

• for training purposes and/or to enhance or review the product or services we provide;
• to conduct statistical analysis and research (where possible, using anonymised data) to improve our website, products/services, marketing, customer relationships and experiences.

To Investigate & Manage Insurance Claims

This means where we need to use the information;

• to investigate accidents, incidents, collisions or other damage to a vehicle on hire from us, or by a vehicle on hire from us to other parties;
• to pass personal details to third-party insurance companies where there is a legal duty to do so, or elsewise where there is a legitimate reason to share this information to deal with an insurance claim.

Legal Obligations

This means where we need to use the information;

•      to prevent, investigate and prosecute crime, fraud and money laundering and for auditing purposes;

•      if we are obliged to disclose information by reason of any law, regulation or court order;

•      to ensure we abide by rules relating to relevant sanctions and politically exposed person (known as PEP) rules;

•      if we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the products/services and financing you have requested or to employ you, or we may stop providing existing services to you;

Note: A record of any fraud or money laundering risks will be retained by the fraud prevention agencies and may result in others refusing to provide services, financing or employment to you. If you have any questions about this, please contact us on the details provided.

General

This means where;

•      the personal data you have provided, we have collected from you, or we have received from third parties will be used to prevent fraud and money laundering and to verify your identity;

•      both we and fraud prevention agencies may also enable law enforcement agencies to access and use your personal data to detect, investigate and prevent crime;

•      we need to process your personal data on the basis that we have a legitimate interest in preventing fraud and money laundering, and verifying identity, in order to protect our business and to comply with laws that apply to us. Such processing is also a contractual requirement of the products or services you have requested;

•      fraud prevention agencies can hold your personal data for different periods of time, and if you are considered to pose a fraud or money laundering risk, your data can be held for up to six years.

Other

We may also;

•      transfer your information to any entity which may acquire rights in us;

•      for any other purpose to which you agree.

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 or by contacting us by email at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of hiring a vehicle.

5. How We Might Share Your Information

We might share your information with the following types of third-party suppliers;

• Our subsidiaries or affiliates, for the purpose of managing our customer relationships, administering our business and providing you with information about other products and services which might be of interest to you;
• Insurance companies with which we work in order to process your application/maintain your contractual obligations for any insurance provided through us.
• Credit and fraud agencies (including Call Credit, Equifax, Experian and CIFAS) to help make decisions (See Section 6: Credit Checking and Automated Decision Making for more information).
• Open Banking providers who provide credit assessment and payment services help make decisions on applications or process payments made to us/made from us via Open Banking (See Section 6: Credit Checking and Automated Decision Making for more information).
• Service providers who need to know the information in order to provide us or you with a product or service, including our third-party service providers who process information/provide services on our behalf to help run some of our internal business operations, including payment systems, email distribution, electronic signature processing, storage of customer documentation, employee service providers, IT services, customer services and for data analytics (using anonymised or pseudonymised data);
• Law enforcement bodies in order to comply with any legal obligation or court order;
• Trade industry bodies who, from time to time, may ask us to provide information about you, such as the Motor Insurance Bureau;
• Where you have been unsuccessful in applying for the product or service with us, but there may be suitable third-party providers who can offer you relevant products/services you may be interested in. In which case, the third-party providers will become the relevant data controller;
• Business advisors to EZOO, for the purpose of assisting us to better manage, support or develop our business and comply with our legal and regulatory obligations;
• Our investors/potential investors or purchasers of us where the information is specifically required to facilitate that investment/purchase (where possible, using anonymised or pseudonymised data);
• Reputable suppliers of products and services that we feel may be of interest to you where you have agreed to receive such marketing;
• Our chosen insurance companies, where you apply for or have, or have had a product service from us or via us, with regard to any application for insurance, claim or attempted claim;
• Debt recovery agencies, service providers, tracing agents or investigators, solicitors or other agents for the purpose of collecting monies or assets due or outstanding on your account;
• Debt purchasers, where have the right to sell performing and non-performing accounts to a third party. However, we will inform you if we do intend to do this on an account you hold with us;
• Entities who may or do acquire any rights in us for the purpose of a business sale or reorganisation;
• In connection to any application for employment in order to validate and assess fitness suitability and eligibility for a role.

Note: If you apply for/have a vehicle hired through the insurance providers, we use will use your personal information to assess your circumstances (including information about any other person whom you choose to be a Named Driver on your policy) and verify the information that you have provided before providing a quote.

As part of your application for vehicle hire, please take time to review the privacy policy of the third-party insurers to ensure you are happy to proceed.

Where there is a change to the insurance provider we use that impacts you, we will inform you of this, and give you an opportunity to review the privacy policy of the third-party insurers to ensure you are happy to proceed.

We, or the insurer or the re-insurer, will exchange information with various databases and registers to help us check the information provided, to detect and prevent crime or fraud and to obtain information about your no-claims history. These may include the Claims and Underwriting Exchange Register run by Insurance Database Services Limited (IDS Ltd), the Motor Insurance Anti-Fraud and Theft Register run by the Association of British Insurers (ABI) and any other relevant industry databases or registers. Information may be shared with these registers, and checks carried out against the information held on these registers when we or the insurer or the re-insurer deal with your request for insurance, at renewal, when amendments are made to your motor policy, where a claim is made or where it is necessary to update our policy records.

Information relating to your insurance policy will be added to the Motor Insurance Database (MID) managed by the Motor Insurers’ Bureau (MIB). MID and the data stored on it may be used by certain statutory and/or authorised bodies, including the Police, the DVLA, the DVANI, the Insurance Fraud Bureau and other bodies permitted by law for purposes not limited to but including:

• Electronic Licensing
• Continuous Insurance Enforcement
• Law enforcement (prevention, detection, apprehension and/or prosecution of offenders)
• The provision of government services and/or other services aimed at reducing the level and incidence of uninsured driving.

If you are involved in a road traffic accident (either in the UK, the EEA or certain other territories), insurers and/or the MIB may search the MID to obtain relevant information. You, or appointed representatives, pursuing a claim in respect of a road traffic accident (including citizens of other countries) may also obtain relevant information which is held on the MID.

Please be aware that any false or incorrect information provided may result in your insurance provider invalidating the quote you are given or may lead to your insurance policy and/or the products/services you have with us relating to this product being cancelled should they lead to a breach of the terms and conditions of the contract. Invalid or false claims may also be recorded by the MIB and/or by the Credit Industry Fraud Avoidance Service (CIFAS) on a centralised database accessible by other MIB/CIFAS members.

6. Credit Checking and Automated Decision Making

Whenever you apply for any of our products and/or services or to make decisions about future products, services, and offers that we think you may be interested in the future we and/or some relevant third parties (such as the insurance company we work with) will use automated, manual or part-automated decisioning processes to assess your application including carrying out checks with credit reference agencies (“CRAs”), including:

• Checks against data relating to your financial situation and financial history. These checks may be referred to as “hard searches” or “credit application searches” and may be visible to other third parties, such as potential lenders;
• Checks against publicly available information such as the Electoral Register, County Court Judgments (CCJs), bankruptcy or repossession information. These checks may be referred to as “soft searches” or “quotation searches” and are visible to only you;
• During the lifetime of an agreement with us, we may complete checks of publicly held information such as the Electoral Register, County Court judgements (CCJ’s), bankruptcy or repossession information, as well as data relating to your financial situation and financial history and these may show as “account management searches” or “portfolio management searches” and are only visible to you.

We may also ask you to provide current account information via our current regulated Open Banking provider or via Bank Statements. This may also be used as part of an automated, manual or part-automated decisioning process to assess your application or the suitability of the current product/service you have with us/through us, or of any other products/services you may be able eligible for. During this process, we may gather information including, but not limited to:

• Your income, including sources of income;
• Transactional information on any accounts you share with us, including patterns of spending, type of transaction, and any references/other information shared by your bank;
• Details of any missed payments, charges, debit or credit interest;
• Payment information (if you choose to make a payment to us via Open Banking or payments are made by us to you via Open Banking).

We will use this information to;

• Assess your creditworthiness and whether you can afford/sustain any payments for a product/service offered by us/through us;
• Verify the accuracy of the data you have provided to us (including identity confirmation);
• Prevent criminal activity, fraud and money laundering;
• Manage your account(s);
• Trace and recover debts;
• Ensure any offers provided to you are appropriate to your circumstances.

We will continue to exchange information about you with CRAs while you have a relationship with us. We will also inform the CRAs about your settled accounts. If you borrow and do not repay in full and on time, CRAs will record the outstanding debt. This information may be supplied to other organisations by CRAs.

When CRAs receive a search from us, they will place a search footprint on your credit file that may be seen by other lenders.

If you are making a joint application, or tell us that you have a spouse or financial associate, we will link your records together, so you should make sure you discuss this with them and share this information with them before lodging the application.

CRAs will also link your records together, and these links will remain on your and their files until such time as you or your partner successfully files for a disassociation with the CRAs to break that link.

The identities of the CRAs, their role also as fraud prevention agencies, the data they hold, the ways in which they use and share personal information, data retention periods and your data protection rights with the CRAs are explained in more detail within the Credit Reference Agency Information Notice (CRAIN). CRAIN is also accessible from each of the three CRAs clicking on any of these links will take you to the CRA’s webpages where you can find details of the CRAIN document: Equifax, TransUnion and Experian.

We will only obtain Open Banking data on the specific accounts you choose to share with us. During the sharing of this data, you will be redirected to your bank/finance provider, and you will be asked to complete authentication with your bank/finance provider through their own security systems. We will not, during this process or at any other time, be privy to, obtain, or seek to obtain any information about other accounts you hold with that provider (other than what can be seen via information to choose to share), or about your login/security details with that provider.

Access to the information you share with us about your account information via Open Banking may last for as long as you wish this access to continue. After 90 days, if we wish to maintain access to this information, we will ask you for a re-confirmation of your consent to access this information. If you do consent to this, we may access your data for a further 90 days. If you do not consent to this continued access/do not respond to any re-consent, then any access to this information will be revoked (please note that any revocation of access to Open Banking data may impact our ability to assess if the products/services we offer/you have with/through us is appropriate, and these product/services may no longer be available to you and/or products/services you hold may be withdrawn).

Whenever fraud prevention agencies transfer your personal data outside of the European Economic Area, they impose contractual obligations on the recipients of that data to protect your personal data to the standard required in the European Economic Area. They may also require the recipient to subscribe to “international frameworks” intended to enable secure data sharing.

Credit scoring is an automated decision. The decision on the provision of credit provided by us is subject to the use of credit scoring, however, may also be subject to a manual review and assessment. If we were to reject your application solely on the basis of a credit scoring system, you can request human intervention and ask us to reconsider your application.

7. Data security

We invest appropriate resources to protect your personal information from loss, misuse, unauthorised access, modification or disclosure, in particular:

• We review our information collection, storage and processing practices, including physical security measures, to guard against unauthorised access to systems.
• We restrict access to personal information to our employees, suppliers, contractors and agents who need to know that information in order to process it for us and who are subject to strict contractual confidentiality obligations. They may be disciplined or their contract terminated if they fail to meet these obligations.

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. Retention of Your Personal Information

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 Rights & Freedoms section below for further information.

In some circumstances we may anonymise or pseudonymise 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. International Transfers

We and the other companies processing your data for the purposes mentioned in Section 5 may, from time to time, need to undertake some of the processing in countries outside of the European Economic Area.

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data. For further details, see https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/international-transfers-after-uk-exit/
• Where we use certain service providers, we may use specific contracts approved for use in the UK, which give personal data the same protection it has in the UK. For further details, see https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/international-transfers-after-uk-exit/

Different privacy laws may apply in these countries, and you understand and unambiguously agree to the transfer of personal information to these countries and parties.

10. Sensitive Personal Information

Sensitive personal data includes information about an individual’s health and other categories of personal information which are closely protected (e.g. criminal convictions). We do not generally process such information unless you have voluntarily provided that information to us (for example, when you have notified us of a health issue).

You agree that, to the extent that you have provided us with sensitive personal data, you provided it voluntarily and agree that we can use any sensitive personal data that you provide us to deliver products or services to you and/or determine your fitness to avail yourself of our products or services. Where possible, we shall seek to minimise the collection and use of such sensitive personal data.

11. Marketing

Where you tell us you are happy to receive information from us we may send you communications products that we perceive may be of interest to you (including in relation to products and/or services of our partners where we have your agreement).

Depending on the contact preferences you select, we will communicate with you by letter, telephone, SMS, email or other electronic means, such as via social and digital media.

If, at any time, you prefer not to receive further communications from us in any or all forms (except in connection with information, products or services that you specifically request), you will have the ability to unsubscribe from such communications by means of a link provided in every e-mail that is sent to you by us or by contacting us (See section on Contact Us below).

12. Refer a Friend

When you refer a friend by giving us their email, you confirm the following:

• That you have obtained the consent of your friend to pass your friend’s details to us and for your friend to receive the e-mail from us.
• That you are happy for us to disclose your details as the person who asked that we send the e-mail to your friend.

We will not use that person’s details for any marketing purposes other than within the terms & conditions listed together with any refer-a-friend forms.

13. Third-Party Websites

Our Privacy Statement does not apply to services offered by other companies or individuals.

Our Privacy Statement does not cover the information practices of other companies and organisations that may advertise our services, and that may use cookies, pixel tags and other technologies to serve and offer relevant ads.

14. Email

Emails sent via the internet can be subject to interception, loss or possible alteration; therefore, we cannot guarantee their security. Although we will do our best to protect your personal information, we cannot guarantee the security of your data sent by email and, therefore, will have no liability to you for any damages or other costs in relation to emails sent by you to us via the internet. If you would like to contact us, please see the section below or use our contact us page.

15. Children’s Privacy

This website is not intended for use by individuals under the age of 18 without the agreement and involvement of a parent or guardian.

We do not knowingly collect personal information from individuals under the age of 18. Where we are able to identify that an individual under the age of 18 has used our services (e.g. the individual may have entered a date of birth into the application form), we will ensure no further processing of the individual’s data takes place except for the purpose of erasing the data.

16. Updates to this Privacy Policy

Our Privacy Policy applies to all of the services offered by us. We will keep this Privacy Policy under review and make updates from time to time. We will not reduce your rights under Privacy Policy without your explicit consent. We will post any Privacy Policy changes on this page, and, if the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of Privacy Policy changes). If you do not accept the amended Privacy Policy, you should stop using the Website; this may affect our ability to provide certain products and services to you. Please see the section regarding Your Rights & Freedoms for further information regarding continued processing.

17. Cookies

Our website uses cookies (including Google Analytics cookies to obtain an overall view of visitor habits and visitor volumes to our Website). To view more information on what cookies we use and how we use them, please review our separate cookie policy.

18. Your Rights & Freedoms

You have a number of rights under Data Protection law including:

• Right to be Informed: We provide all customers with this privacy policy to provide transparent and clear information as to arrangements for the collection, control and processing of personal data.
• Right of Access: Copies of personal data held can be requested under an access request and will be met in the 30-day legislative standard ordinarily free of charge. Any extension to these requirements will be advised on the basis of the nature of the request but will be by exception and subject to senior management scrutiny; please see the contact us section for further detail.
• Right to Rectification: In the event, we hold inaccurate data, please advise us of the correct information, and records will be updated within 72 hours, and confirmation will be provided accordingly (Subject to satisfactory verification of your identity).
• Right to Restriction of Processing: You have the right to restrict the processing of your personal data where you have a particular reason for wanting the restriction.
• Right to Object: You can object to our processing on the basis that this is contrary to your rights and freedoms; any objection relating to direct marketing will be acted upon within 48 working hours, and other objections will be treated as a complaint and assessed against our documented legal basis.
• Right to Erasure: Commonly known as the right to be forgotten, we will adhere to your request ordinarily within 72 working hours where the legal basis is solely or partially established as consent, any data required for legal, regulatory or legitimate interests may be maintained in accordance with documented retention schedules. However, our team will confirm and discuss your request to ensure your rights and freedoms are observed at all times.
• Right to Data Portability: You have the right to receive the personal data that you provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller in a timely manner, generally 72 working hours unless evidenced to be unduly excessive or unreasonable.

You have a further right in connection with automated decisions; however, this is covered in the relevant section of this statement.

We have established robust policy and procedural requirements to enable your rights as a data subject to be adhered to; however, where this is not possible for the reasons outlined, we confirm the detail.

In relation to all of these rights, please write to or contact us via one of the methods provided in section 1. Please note that we will need to verify your identity.

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.

19. Complaints Process

If you have a complaint about how we have handled your personal information, you may contact us using the details below, and we will investigate your complaint. You also have the right to lodge a complaint with a supervisory authority (i.e. the ICO) once you have tried to resolve the issue with us.