Privacy Notice – May 2015
UnityLink Financial Services Limited understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our customers and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
- Information About Us
UnityLink Financial Services Ltd is a limited company registered in England under company number 03547586.
Our registered office is at 158-160 Balham High Road,London,SW12 9BN.
Our principal place of business is at 158-160 Balham High Road,London,SW12 9BN.
Data Protection Officer: Kevin Basson
Email: info @unitylink.com
- What Does This Notice Cover?
This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
- What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
The personal data that we use is set out in Part 5.
- What Are My Rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
- The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
- The right to access the personal data we hold about you. Part 10 will tell you how to do this.
- The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
- The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 11 to find out more.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to us using your personal data for a particular purpose or purposes.
- The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
- Rights relating to automated decision-making and profiling. We do not use your personal data in this way, including automated decision-making or profiling.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
- What Personal Data Do You Collect?
The personal data we collect and process may include, among others:
- Your name;
- Your contact information such as Your address and email address and telephone number (or any telephone number used to call our customer services);
- Your demographic information such as age and gender;
- Evidence of Your identity (for example passport information);
- unique identifiers such as username, account number and password;
- Your profiles and postings on any other social media applications and services that we provide or that You make available to us;
- Your payment details or other financial data, e.g.: Your bank or payment method provider’s name, or your account number, sort code and billing address; and
- information about Your visit to our website, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page.
We also collect from You information in relation to other people (e.g.: details of the recipients of Your money transfers), where You provide us with such information. By providing us with such information you confirm that you have obtained any necessary permissions from such persons to the reasonable use of their information for such purposes in accordance with this notice, or are otherwise permitted to give us this information on their behalf. Please also ensure that those other people are aware of this notice and that the provisions of this notice are clearly communicated to them.
- How Do You Use My Personal Data?
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Our primary purpose in collecting user information is to provide You with a safe, smooth, efficient, and customised experience and to provide the services You have requested from us. We may also use the information that You have provided to ensure that the content on our site is presented in the most effective manner for You and Your computer or device.
We use Your information for the following specific purposes:
- to register You with a UnityLink account;
- to fulfil Your Transaction Request;
- to send You confirmations;
- to notify You about changes to our services;
- to prevent fraud;
- to ensure that content from our site is presented in the most effective manner for You and for Your computer;
- to send You marketing communications, provided that You have given us Your contact details in the course of a sale (or of negotiations for a sale) of our products or services and that you do not decide to opt out from this type of communications, in accordance with Data Protection Legislation (including the European Directive 2002/58/EC and The Privacy and Electronic Communications (EC Directive) Regulations 2003).
- to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- as part of our efforts to keep our site and our services safe and secure;
- to measure or understand the effectiveness of advertising we serve to You and others, and to deliver relevant advertising to You;
- to make suggestions and recommendations to You and other users of our site about services that may interest You or them; and
Legal grounds for using Your personal information
The law permits us to process Your personal data in the way we do because the processing is:
- necessary for the purposes of the legitimate interests that we pursue, which are:
- to run and administer our business;
- to prevent fraud;
- to provide you with our services;
- to evaluate, develop or improve our services;
- to keep you informed about relevant products and services you are using;
- to discharge our legal obligations to store and disclose information where necessary; and/or
- to provide You with an efficient and smooth customer experience;
- necessary for the performance of our contract with You to provide You with our services;
- necessary in order to comply with a legal obligation to which we are subject; or
- permitted by You, because You have given us consent.
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email and telephone with information, news, and offers on our products and services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
- How Long Will You Keep My Personal Data?
We will only keep the information we collect about You for as long as required for the purposes set out above, or as required to comply with any legal obligations to which we are subject. This will involve us regularly reviewing our files to check that information is accurate, up-to-date and still required.
The period for which we will retain information about You will vary depending on the type of information and the purposes that we use it for. In general, we will keep our records for up to 7 years after you have terminated your relationship with us, in order to comply with our legal obligations.
We may retain Your contact information collected for the purposes of sending You marketing communications in accordance with this policy for as long as You do not unsubscribe from receiving the same from us.
- How and Where Do You Store or Transfer My Personal Data?
Data that You submit via our site or Mobile App is sent to and stored on secure servers owned by, or operated for, us in the EEA. Data may be transferred to, or stored at, a destination outside the European Economic Area (“EEA“) and may also be processed by staff operating outside the EEA who work for us, or for one of our service providers, related companies, agents or contractors. Such transfers may be made in order to operate the service, improve our site, Mobile App or services, or to assist in our security or fraud protection activities.
Where recipients are outside the EEA, we ensure that they provide an adequate level of protection for Your personal data or that the transfer is otherwise permitted under applicable Data Protection Legislation, by methods including using standard contractual clauses, binding corporate rules, registration for the Privacy Shield program, or by relying on a relevant adequacy decision by the European Commission or on other legal grounds or conditions, always in accordance with applicable Data Protection Legislation.
Where we feel it is necessary or appropriate we may seek to rely on Your consent as the legal basis for transferring Your personal data to outside the EEA, however we do not generally do so. Where we do, You may withdraw Your consent at any time.
- How do we protect Your information?
We ensure that there are appropriate technical, physical, electronic, and administrative safeguards in place to protect Your personal details from unauthorised access. When You may enter certain information such as a credit card number on our order forms, we encrypt the transmission of that information using reasonable security measures. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it.
Unfortunately, the transmission of information via the internet (including by email) is not completely secure. Although we will do our best to protect Your personal data, we cannot guarantee the security of Your data transmitted to our site; any transmission is at Your own risk. Once we have received Your information, we will use strict procedures and security features to try to prevent unauthorised access.
- Do You Share My Personal Data?
We may sometimes contract with third parties to supply products and services to you on our behalf. These may include payment processing and marketing. In some cases, those third parties may require access to some or all of your personal data that we hold.
- We may disclose data to provide our services, to respond to legal requirements, enforce our policies, liaise with judicial or regulatory authorities where required under applicable law, and protect our rights and property.
- The personal information You provide to us may also be shared with third party companies, agents, contractors, service providers or related companies, including without limitation:
- with credit reference agencies to verify Your identity or recipients of the money transferred through the Service, if this is necessary to provide You with our services, respond to Your enquiries or for any other related purposes, and
- with fraud prevention agencies who may use it to prevent fraud and money-laundering and to verify Your identity (please note that those who commit fraud can be refused services, finance or employment. Further details of how Your information will be used by us and these fraud prevention agencies can be found by contacting us at email@example.com.
- We may also share Your personal information with:
- other companies we have instructed to provide services to or for us;
- other third parties for those purposes that may be reasonably ascertained from the circumstances in which the information was submitted;
- other business entities, should we plan to merge with, or be acquired by, or be invested in by that business entity, or if we undergo a corporate re-organisation;
- any successor in interest, in the event of a liquidation or administration of UnityLink Financial Services Limited; and
- to any other third party, but only subject to Your prior consent.
Links to Other Sites
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
- How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 12.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within 14 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
- How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Kevin Basson):
Telephone: 0208 772 2160
Post: 158-160 Balham High Road,London,SW12 9BN
- Changes to this Privacy Notice
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection. Any changes will be made available on our website : www.unitylink.com