My personal data is data which by itself or with other data available to you can be used to identify me. You are Lifelines Limited, the data controller. This data privacy notice sets out how you'll use my personal data. I can contact your Data Protection Officer (DPO) at 1 Tannery House, Tannery Lane, Send, Woking, Surrey GU23 7EF, if I have any questions.
The types of personal data you collect and use
Whether or not I become a customer, you'll use my personal data for the reasons set out below and if I become a customer you'll use it to manage my account and services that I've applied for. You'll collect this directly from my initial enquiry, business card and / or existing account information. The sources of personal data collected indirectly are mentioned in this statement.
The personal data you use may include:
a. Full name and personal details including contact information - i.e. Company name, position, business address, telephone number(s), mobile telephone number(s), website, email address(es) and specialist interests;
b. Records of products and services that I've purchased, rented or subscribed to;
c. Warranty, product and service call history;
d. Payment history;
e. If applying for a credit terms, information from credit references or fraud prevention agencies, electoral roll, court records of debt judgements and bankruptcies and other publicly available sources.
Providing my personal data
You'll tell me if providing some personal data is optional, including if you ask for my consent to process it. In all other cases I must provide my personal data so you can process my enquiry (unless I'm a customer and you already hold my details).
Using my personal data: the legal basis and purposes
You'll process my personal data:
1. As necessary to perform your contract with me for the purchase of goods and / or services:
a. To take steps at my request prior to entering into it;
b. To decide whether to enter into it;
c. To manage and perform that contract;
d. To update your records; and
e. To trace my whereabouts to contact me about my account and recovering debt.
2. As necessary for your own legitimate interests or those of other persons and organisations, e.g:
a. For good governance, accounting, and managing and auditing your business operations;
b. To search at credit reference agencies;
c. To monitor emails, calls, other communications, and activities on my account;
d. For market research, analysis and developing statistics; and
e. To send me marketing communications.
3. As necessary to comply with a legal obligation, e.g.:
a. When I exercise my rights under data protection law and make requests;
b. For compliance with legal and regulatory requirements and related disclosures;
c. For establishment and defence of legal rights;
d. For activities relating to the prevention, detection and investigation of crime;
e. To verify my identity, make credit, fraud prevention and anti-money laundering checks; and
f. To monitor emails, calls, other communications, and activities on my account.
4. Based on my consent, e.g.:
a. When I request you to disclose my personal data to other people or organisations such as a company handling a claim on my behalf, or otherwise agree to disclosures;
b. When you process any special categories of personal data about me at my request; and
c. To send me marketing communications where you've asked for my consent to do so.
I'm free at any time to change my mind and withdraw my consent. The consequence might be that you can't do certain things for me.
Sharing of my personal data
Subject to applicable data protection law you may share my personal data with:
a. The Lifelines group of companies* and associated companies in which you have shareholdings;
b. Lifelines distributors and other persons who help to provide your products and services;
c. Third party companies and other persons providing services to you;
d. Your legal and other professional advisors, including your auditors;
e. Fraud prevention agencies, credit reference agencies, and debt collection agencies when you open my account and periodically during my account or service management;
f. Other organisations who use shared databases for income verification and affordability checks and to manage/collect arrears;
g. Government bodies and agencies in the UK and overseas (e.g. HMRC who may in turn share it with relevant overseas tax authorities and with regulators e.g., the Prudential Regulation Authority, the Financial Conduct Authority, the Information Commissioner's Office);
h. Courts, to comply with legal requirements, and for the administration of justice;
i. In an emergency or to otherwise protect my vital interests;
j. To protect the security or integrity of your business operations;
k. To other parties connected with my account e.g. guarantors;
l. When you restructure or sell your business or its assets or have a merger or re-organisation;
m. Market research organisations who help to improve your products or services;
n. Anyone else where you have my consent or as required by law.
My personal data may be transferred outside the UK and the European Economic Area. While some countries have adequate protections for personal data under applicable laws, in other countries steps will be necessary to ensure appropriate safeguards apply to it. These include imposing contractual obligations of adequacy or requiring the recipient to subscribe or be certified with an 'international framework' of protection.
Credit reference checks
If I've applied for a credit terms then in order to process my application, you'll perform credit and identity checks on me with one or more credit references / agencies. To do this you'll supply my personal data to the credit references / agencies and they'll give you information about me.
My marketing preferences and related searches
You'll use my business address, phone numbers, email address and social media (e.g. Facebook, Google and message facilities in other platforms) to contact me according to my preferences. I can change my preferences or unsubscribe at any time by contacting you. In the case of social media messages, I can manage my social media preferences via that social media platform.
If I don't want information on other products and services or to be included in market research, and I haven't told you before, I can let you know by contacting your Data Protection Officer (DPO) at 1 Tannery House, Tannery Lane, Send, Woking, Surrey GU23 7EF
Criteria used to determine retention periods (whether or not I become a customer)
The following criteria are used to determine data retention periods for my personal data:
a. Retention in case of enquiries. You'll retain my personal data as long as necessary to deal with my enquiry and to assist me in future with similar enquiries;
b. Retention in case of claims. You'll retain my personal data for as long as I might legally bring claims against you; and
c. Retention in accordance with legal and regulatory requirements. You'll retain my personal data after my account, or service has been closed or has otherwise come to an end based on your legal and regulatory requirements.
My rights under applicable data protection law
My rights are as follows (noting that these rights don't apply in all circumstances and that data portability is only relevant from May 2018):
a. The right to be informed about your processing of my personal data;
b. The right to have my personal data corrected if it's inaccurate and to have incomplete personal data completed;
c. The right to object to processing of my personal data;
d. The right to restrict processing of my personal data;
e. The right to have my personal data erased (the "right to be forgotten");
f. The right to request access to my personal data and information about how you process it;
g. The right to move, copy or transfer my personal data ("data portability"); and
h. Rights in relation to automated decision making including profiling.
i. I have the right to complain to the Information Commissioner's Office. It has enforcement powers and can investigate compliance with data protection law: ico.org.uk.
For more details on all the above I can contact your DPO.
Data anonymisation and aggregation
My personal data may be converted into statistical or aggregated data which can't be used to identify me, then used to produce statistical research and reports. This aggregated data may be shared and used in all the ways described above.
Last updated: May 22, 2018
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