Some terms we use in this policy may be difficult to understand so we’ve provided a breakdown below to help you clarify what we mean.
LAWFUL BASIS
Legitimate Interest means the interest of our business in managing and carrying out our business functions so that we can give you the highest quality services/products and the best and most secure experience. We consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We will not use your personal data where our interests are overridden by your fundamental rights (unless we have your consent or are required or permitted to by law). If you need further detail on how we assess our legitimate interests against any potential impact on you in relation to certain circumstances, please contact us.
Performance of Contract means processing your data where you are a party to a contract and we need your personal data in order to carry out that contract or to take steps at your request if you are thinking of entering into a contract with us.
Legal obligation means processing your personal data where we have to comply with a law that applies to us.
Consent means you have specifically let us know that we can process your data for the purpose already given to you.
EXTERNAL THIRD PARTIES
• Website Hosts – In this instance Cogent (www.cogent.co.uk) are the host of this website;
• Merchant Services providers;
• Providers of accident management systems, insurance managers and claims handlers;
• Agencies providing distribution services for marketing materials and or service information, whether electronic or in hard cop
• Credit reference agencies;
• HMRC, regulators or other authorities as necessary;
• Providers of prizes or incentives in relation to competitions, promotions or surveys;
• Share registration and management service providers;
• IT Systems and administration services providers;
• Advisors or agencies acting on our behalf such as solicitors, auditors, insurers, registrars and collections agencies;
YOUR LEGAL RIGHTS
This is a breakdown of what each of your rights mean and the results you can expect when you enact them.
• Right of Access to your personal data – This is usually called a ‘Subject Access Request’. You can request a copy of personal data to see what we hold about you and to check why & how we are processing it and that we are processing it lawfully. We may be required to suitably redact (obscure) elements of the requested detail to protect the rights and personal data of other individuals.
• Right to rectification of your personal data – If you recognise any of the personal data we hold on you to be incorrect or incomplete you can request it to be corrected. In certain circumstances, we may require proof of accuracy of any new data being submitted.
• Right to erasure of your personal data – If you believe there is no fair reason for us to hold an element of your personal data, you can ask us to remove or delete this from our records, On occasion you may want to exercise this right on a successful objection to processing (see definition below). If for any reason, for example, to comply with a legal obligation, we cannot delete your personal data we will action your request as far as possible and provide to you a reason as to why we cannot fully comply with your request.
• Right to object to processing of your personal data – If we rely on legitimate interest as our legal basis for processing or the legitimate interest of another third party, you can object to our processing if you feel it impacts your fundamental rights and freedoms. We will reassess the legitimate grounds we have for processing your data and on occasion we may demonstrate that they are sufficient in overriding your rights and freedoms. Specifically in relation to direct marketing, please see the section above entitled ‘Marketing’.
• Right to restrict processing of your personal data – You can ask us to temporarily pause the processing of your personal data in certain circumstances. For example:
• If you have objected to our processing of your personal data, but we are assessing whether our legitimate grounds override your rights and freedoms.
• If you want to ensure that it is correct or complete before we continue to use it.
• If we are processing the data unlawfully but you do not want us to delete it.
• If you ask us to keep the data where we no longer need it, as you require it to establish, exercise or defend legal claims.
• Right to data portability – This applies to automated information originally received on the lawful basis of consent or performance of contract. You can ask for a copy of the related data and for it to be transferred to a third party of your choosing in a commonly used, machine readable format.