Inchora Commercial Limited respects your privacy and is committed to protecting your personal data. This privacy notice will inform you how we look after your personal data if the following circumstances:
- When you visit our website.
- It will also explain how we look after your data when you provide it to us direct.
- Or indirect via a third party such as a Letting Agent or Referencing company.
- It also covers how we look after your information when you provide it to us direct usually via phone in order to obtain a quote or make a purchase.
This policy is set out as follows:
- Important Information and who we are
- The Data we collect about you
- How is your personal data collected
- How we use your personal data
- Disclosures of your personal data
- International Transfers
- Data Security
- Data Retention
- Your Legal Rights
- Financial Conduct Authority (FCA)
1. IMPORTANT INFORMATION AND WHO WE ARE
Who We Are
Inchora Commercial Limited (Collectively referred to as “Inchora Commercial”, “we”, “us” or “our” in the privacy notice) is a company which is incorporated in England & Wales with the company registered number 06771616 , whose registered office is at Building X92, Cody Technology Park, Farnborough, Hampshire, GU14 0LX and is registered under the Data Protection Act Z1597167
Inchora Commercial Limited is a subsidiary of Inchora Limited (incorporated in England & Wales with company registered number 07890586, whose registered office is at Building X92, Cody Technology Park, Farnborough, Hampshire, GU14 0LX). The Inchora family undertakes a diverse range of activities, a number of which are regulated by statute.
Where you have provided your personal data to us directly we will be the Data Controller, and where we have received your personal data via a third party we will perform the role of a Data Processor on behalf of the Data Controller.
We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your rights under the Data Protection Act please contact the DPO using the details set below.
The Data Protection Officer
Inchora Commercial Limited
Cody Technology Park
Old Ively Road
Email address: Dataprotection@inchora.com
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority 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 NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
This privacy notice was last updated on the 07th November 2018
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.
Our website may include links to third-party websites, plug-ins and applications. 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 notice of every website you visit.
2. THE DATA WE COLLECT ABOUT YOU
Personal data, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes first name, maiden name, last name, employment status, marital status, title, date of birth and gender.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Property Data includes type, number of rooms, locks, energy usage
- Health Information any medical conditions that may affect a claim for protection insurance
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data includes 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.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Evidence of consent IP address, webpage access, time stamp
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Call Recordings Records of your conversations with us
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does 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 notice.
Special category data
Certain types of personal data are considered more sensitive and so are subject to additional levels of protection under data protection legislation. These are known as ‘special categories of data’ and include data concerning your health, racial or ethnic origin, genetic data and sexual orientation. Data relating to criminal convictions or offences is also subject to additional levels of protection.
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 provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3. 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, Energy Supplier and Usage by filling in online forms or by phone. This includes personal data you provide when you:
- apply for our products or services;
- request marketing to be sent to you;
- give us some feedback.
- Call recordings
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data from the following parties:
- analytics & tracking providers some such as Google based outside the EU;
- Google Tag Manager
- Google Analytics
- Inchora Session
- advertising networks based inside & outside the;
- Google Adwords
- Bing Ads
- Google Display Network
- PPC Protect
- Facebook ads
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Credit Card Authorisation based inside the EU.
- From your landlord or head office.
- Third party software and applications where you are given the choice to share data with us:
- Confirmation and status of services arranged by us from third party provider on your behalf. Example Energy Switch still pending or compete. Third parties we receive information from are:
- Energy Providers
- Media providers
- Insurance providers
4. HOW WE USE YOUR PERSONAL DATA
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 contract 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 or regulatory obligation.
We only rely on consent as a legal basis for processing your personal data in relation to marketing communications to you via phone, email or text message. You have the right to withdraw consent to marketing at any time by Contacting us.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground 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 where more than one ground has been set out in the table below.
|Type of data
|Lawful basis for processing including basis of legitimate interest
|To register you as a new customer
|Performance of a contract with you
|Property Utility Notifications||(a) Identity
|Legitimate interest of the landlord|
|To produce your comparisons and quotes including:
(a) Energy comparisons
(b) Media choices
(c) Insurance quotes
(e) Product preferences
(f) Marketing and Communications
|Performance of a contract with you
|Call Recordings for:
(a) Proof of contract
(b) Record of conversation
(c) Assessing quality of sale
(d) Training Purposes
(e) Prevention & detection of crime.
All types of data mentioned in this chart
|(a) Necessary for our legitimate interest to monitor sales quality and provide evidence in disputes over sales
(b) Performance of contract with providers
|To process your order including:
Managing payment methods, and take deposits
(e) Marketing and Communications
|(a) Performance of a contract with you
|To offer you membership to MySelect Club||(a) Identity
|To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(d) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
|(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
(e) Marketing and Communications
|Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
|To make suggestions and recommendations to you about goods or services that may be of interest to you
|Necessary for our legitimate interests (to develop our products/services and grow our business)
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
PROMOTIONAL OFFERS FROM US
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any company outside the Inchora group of companies for marketing purposes.
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 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 a product/service purchase or other transactions.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
- Internal Third Parties as set out in the Glossary.
- External Third Parties as set out in the Glossary.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. INTERNATIONAL TRANSFERS
Your personal data may be processed in countries outside of the European Union (EU) Where we transfer your personal data to countries that are outside of the EU we will ensure that the transfer is carried out in a compliant manner and appropriate safeguards are in place and in accordance with the relevant data protection requirements
7. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. The Inchora Group is Cyber Essentials Certified. [There is no such legal entity as Inchora Group. Is it Inchora Limited that has the certification?] In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
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. DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 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 Request erasure below for further information.
In some circumstances we may anonymise 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. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
If you wish to exercise any of the rights set out above, please Contact us
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 may 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 may 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.
10. FINANCIAL CONDUCT AUTHORITY (FCA)
Who regulates us?
Inchora Commercial Limited is an appointed representative of Albany Park Limited, Cody Technology Park, Old Ively Road, Farnborough, Hampshire, GU14 0LX which is authorised and regulated by the Financial Conduct Authority. Financial Services Register number for Albany Park Limited is 304130 and 679090 for Inchora Commercial. You can check this on the Financial Register by visiting the FCA’s website http://register.fca.org.uk or by contacting the FCA on 0800 111 6768.
Who is The Financial Conduct Authority (FCA)
The FCA is the independent watchdog that regulates financial services. It requires us to give you this information. You should use this information to decide if our services are right for you.
Complaints procedure If you wish to register a complaint regarding Insurance products, please contact us:
- By email: please send us your complaints to: firstname.lastname@example.org
- By phone: call us on 01252 912181
- In writing: send a letter to: Alan Webster
Cody Technology Park,
We will then investigate your complaint and get back to you. If you cannot settle your complaint with us, you may be entitled to refer it to the Financial Ombudsman Service.
Please see link for further details: http://financial-ombudsman.org.uk
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure 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 do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by Contacting us
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
INTERNAL THIRD PARTIES
Other Inchora Group Companies may act as joint controllers or processors and provide IT and system administration services, Accounting Services, Compliance, Marketing and Communication Services and undertake leadership reporting.
“Group Company/ies” shall mean Inchora Limited and any other entity that, directly or indirectly through one or more intermediaries, controls, is controlled by, or is under common control with, Inchora Limited.
EXTERNAL THIRD PARTIES
- Service providers acting as processors based in the United Kingdom who provide:
- IT and system administration services.
- Comparison and sales services
- Incumbent Energy Providers
- Feedback and service references
- Provide API links between Letting Agents software and our own software
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
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