Privacy Policy

LAST REVISED: 15/05/2018


We understand that your privacy is important to you and that you care about how your personal data is used and shared. We respect and value the privacy of everyone and will only collect and use personal data in ways that are described here, and in a manner that is consistent with our obligations and your rights under the law.


Monitoring of Communications

Subject to applicable laws, we will monitor and record calls, email, text messages, social media messages and other communications. We will do this for compliance with regulatory rules, self-regulatory practices or procedures relevant to our business, to prevent or detect crime, in the interests of projecting the security of our communication systems and procedures, and for quality control and staff training purposes.

Where appropriate and having regard to applicable data protection law our monitoring will be to check for obscene or profane content in communications. In very limited and controlled circumstances we may conduct short term carefully controlled monitoring of your activities where this is necessary for our legitimate interests or to comply with a legal obligation.


Using and Processing your Personal Information: the Legal Basis and Purposes

The legal basis which relates to our use and other processing of your personal information may include (as relevant):

Processing that is necessary for our own legitimate interests or those of third parties:

a) For management and audit of our business operations, including accounting;

b) When we monitor emails, calls and other communications and activities in relation to your requirements;

c) For market research and analysis, developing statistics; and

d) For our own direct marketing communications which we send to you about our own products and services;

Processing that is necessary to comply with a legal obligation to which we are subject other than a contractual obligation such as:

a) To process your request for personal information or when you seek to exercise your rights against you under data protection law;

b) For compliance with legal and regulatory requirements we may sometimes need to collect it, use it, or disclose it because of a legal or regulatory responsibility;

c) For establishment and defence of legal rights;


Sharing your Personal Information

We share your personal information with the following parties:

a) Our legal and professional advisers, such as our auditors and external legal advisors in the events of, for example, sale or restructuring of our business;

b) Other third parties and/or sub-contractors acting on the behalf, such as back up and server hosting providers, our IT software and maintenance providers; and

c) Purchasers of any part of our business, and their professional representatives;


International Transfers

Your personal information may be transferred outside the UK and the European Economic Area.


Identity Verification and Fraud Prevention Checks

The personal information we have collected from you could be shared with fraud prevention agencies that will use it to prevent fraud and money-laundering and to verify your identity.


Retention Periods or Criteria used to determine the Retention Period

We need to keep your personal information for as long as necessary to fulfil the purposes for which it was collected (and those purposes are as described above). This includes retaining it in order to comply with legal and regulatory requirements and in case of claims. If you would like further information about our data retention policy, contact our Data Protection Officer.


The criteria we use to determine data retention periods for your personal information includes

Retention in case of queries. We will retain it in case of queries from you;

Retention in case of claims. We will retain certain parts of your personal information for the period in which you might legally bring claims against us; and

Retention in accordance with legal and regulatory requirements. We will carefully consider whether we need to retain your personal information after the period described above in case of legal or regulatory requirement;


Your Rights under applicable Data Protection Law

Your personal information is protected under data protection law and you have a number of rights which you can enforce against us as your data controller. You should be aware that these rights do not apply in all circumstances. If you seek to exercise one against us it will at that stage be explained to you whether or not the right does apply to you based on the facts.

Your rights are as follows:

The right to be informed;

To have your personal information corrected if it is inaccurate and to have incomplete personal information completed in certain circumstances;

The right in some cases to restrict processing of your personal information;

The right to have your personal information erased in certain circumstances (also known as the 'right to be forgotten');

To request access to the personal information held about you and to obtain certain prescribed information about how we process it;

To move, copy or transfer certain personal information. Also known as 'data portability';

Rights in relation to some automated decision making about you including profiling (as relevant) if this has a legal or other significant effect on you as an individual;

The right to complain to the Information Commissioner's Office who is empowered to investigate whether we are complying with the data protection law. You can do this if you consider that we have infringed it. You can visit its website for more information: www.ico.org.uk.

For more information about all of these rights and how to exercise them against us, you can contact us by Telephone: 0203 841 1045 or write to Thamesgate House, 33-41 Victoria Avenue, Southend-on-Sea, Essex, SS2 6DF.